Veterans Health Administration (VHA) Commercial Air Patient Transport

FSS Sole Source Justification Department of Veterans Affairs (VA), Veterans Transportation Program (VTP) Page 10 of 10 DEPARTMENT OF VETERANS AFFAIRS Office of Acquisition, Logistics, and Construction Office of Procurement, Enterprise Procurement Office (EPO) 5202 Presidents Ct, Suite 103 Frederick, MD 21703 Federal Supply Schedule (FSS) Sole Source Justification (Prepared in accordance with RFO 8.401, GSAR 538.7104-3(b)(2) and format guidance provided within the Federal Acquisition Regulation (FAR) Companion, FC 8.401(b)) Identification of the agency and the contracting activity, and specific identification of the document as an "FSS Sole Source Justification." This Federal Supply Schedule (FSS) Sole Source Justification supports an FSS Task Order to be executed by the Department of Veterans Affairs (VA), Enterprise Procurement Office (EPO), on behalf of the Veterans Transportation Program (VTP) within the Veterans Health Administration (VHA). Nature and/or description of the action, including a description of the supplies or services required to meet the agency s needs and the estimated value. VA proposes to award a non-competitive FSS task order to Duluth Travel Inc. (Duluth) to provide commercial air travel booking services for Beneficiary Travel. This program arranges air transportation for eligible Veterans who must travel outside their normal commuting area to receive authorized medical care. Supporting Beneficiary Travel, the contractor will provide: Reserving, booking, and ticketing of refundable airfare; Coordination of specialized airline accommodations (wheelchair assistance, etc.); VHA-compliant processing, documentation, communications and invoicing; Cancellations, exchanges, and itinerary management; 24/7 service support. VA will award this task order under Duluth Travel Inc.'s existing General Services Administration (GSA) Multiple Award Schedule (MAS) contract, number 47QMCB25D0001, issued under the Travel Agent Services category 561510. Duluth Travel Inc., a Small Business Administration (SBA) certified Service-Disabled Veteran-Owned Small Business (SDVOSB), is located at 2860 Peachtree Industrial Blvd., Ste 1000, Duluth, GA 30097-7906. Duluth is the sole SDVOSB under this MAS, there are no other SDVOSBs under this MAS. The value of this task order is $29,131,085.00 over a 12-month period of performance. This amount covers the cost of medically authorized Veteran airfare, refundable ticket fees, airline-imposed fees, and Duluth's per-transaction service fees for domestic and international bookings, discounted from Duluth's MAS contract. CLINS Description/ Est. Cost 0001: Commercial Air Transport Actual cost of plane ticket to include taxes and airline fees 0002: Published FSS Svc. Fee (Full Service) *discounted Domestic: Fee ($)/Ticket International: Fee ($)/Ticket Exchanges: additional service fee is applied Refunds: initial service fee is retained. The authority and supporting rationale (see GSAR 538.7104-3(b)(1)) and, if applicable, a demonstration of the proposed contractor s unique qualifications to provide the required supply or service. Authority: The statutory exception supporting the placement of this order on a sole source basis is RFO 8.401, specifically GSAR 538.7104-3(b)(1)(i): "The need is of such unusual urgency that following the procedures would result in unacceptable delays in fulfilling that need." Supporting Rationale: This contract action is necessary to prevent interruption in medically required Veteran travel services, maintain compliance with VHA Beneficiary Travel policy, and ensure Veterans can access authorized care when they cannot self-fund initial transportation. Beneficiary Travel booking support is a continuous, high-volume function: Veterans rely on it daily to reach specialty and other medical appointments that are frequently unavailable at their local facility. Any gap in this support does not simply delay administrative processing, it directly interrupts Veterans' ability to reach medically necessary care, including time-sensitive and recurring treatment. Many Veterans who require medically necessary travel cannot afford to purchase airline tickets up front and wait for reimbursement. This creates a significant barrier to accessing care, particularly for those needing life-saving transports. Without a contracted solution, Veterans may be unable to attend appointments, risking serious harm or adverse outcomes. The vendor is essential to ensure timely, reliable access to travel arrangements for these individuals. A full and open competitive acquisition for a requirement of this scope, scale, and specialized operational alignment would require sufficient time for solicitation development, a meaningful proposal preparation period, technical and price evaluation, and award and transition. That timeline extends well beyond the period VA can sustain without a booking mechanism in place. Compressing a competitive process to fit within a shorter window would itself create unacceptable risk of a flawed evaluation, increased protest exposure, and further delay, outcomes that would compound rather than resolve the urgency. Awarding to Duluth under its existing MAS contract avoids this gap entirely, because Duluth already maintains VA-specific workflows and operational infrastructure and can begin performance immediately upon award, without the stand-up period a new awardee would require. Absent this action, Veterans would be forced to self-arrange and self-fund travel to authorized care, or VA staff would need to revert to manual, non-automated processing, both of which increase the risk of missed or delayed medical appointments, disrupted continuity of care, and adverse outcomes for Veterans who depend on timely transportation to reach treatment not available locally. Contractor's Unique Qualifications: The VA's VTP office identified an urgent and compelling need to contract with a responsible source that can immediately mobilize and meet VA's specialized operational requirements for Beneficiary Travel. These requirements exceed standard commercial travel booking and include: compliance with VHA Beneficiary Travel policy and Federal Travel Regulation eligibility and reimbursement rules; coordination of medical accommodations (e.g., wheelchair assistance, oxygen needs) for a medically vulnerable traveler population; rapid, time-critical itinerary turnaround to prevent missed medical appointments; 24/7 booking and rebooking support; VHA-compliant documentation, invoicing, and reconciliation integrated with VA's internal systems; and nationwide scalability to serve Veterans across dispersed VA and community care sites. Market research confirmed that while 21 MAS 561510 holders offer general commercial travel services, only Duluth demonstrated existing infrastructure and experience aligned to these requirements, including established VA-specific workflows, proven nationwide scalability, and a track record supporting VA's travel programs. Duluth is uniquely qualified due to: VA-specific workflow experience; Ability to rapidly deploy nationwide medical travel support; SDVOSB socioeconomic alignment; Proven responsiveness and operational readiness; and Existing infrastructure already supporting VA travel programs. No other MAS vendor demonstrated the combination of VA-specific workflow experience, nationwide operational readiness, and SDVOSB status required to stand up compliant Beneficiary Travel support without impacting Veteran care. The impact on Veteran care is significant. While VA policy provides for medically necessary travel, the actual provision of these services is inconsistent across facilities. Due to Anti-Deficiency Act constraints, many VA facilities are unable to provide transport directly, resulting in Veterans paying out of pocket for airfare and related travel expenses. Many Veterans cannot afford to front these costs, which creates a substantial barrier to accessing authorized medical care, especially for those requiring life-saving transports. Without a contracted solution, Veterans risk missing critical appointments or foregoing necessary treatment altogether. It is essential to ensure timely, reliable access to travel arrangements for these individuals, and any delay in awarding this contract could directly impact Veteran health and safety by preventing access to care. Although no documented metrics are available, the situational need and the unique readiness of Duluth Travel Inc. provide compelling justification for limiting sources under GSAR 538.7104-3(b)(1)(i). This capability is not merely administrative: under the standard reimbursement process, a Veteran who cannot afford airfare out of pocket has no way to book travel to a required appointment, since reimbursement occurs after the trip. This task order allows VA to book and pay for airfare directly and in advance, ensuring Veterans who cannot self-fund travel are not prevented from reaching authorized care. Duluth's existing MAS contract and established VA-specific processes provide the readiness to begin performance immediately upon award. A determination by the ordering activity contracting officer that the order represents a fair and reasonable price consistent with RFO 8.401, specifically GSAR 538.7102-2(d)(2) and 538.7104-2(a)(3). The Contracting Officer has determined that the anticipated cost to the Government for the services covered by this justification will be fair and reasonable, with supporting rationale documented in a best value determination prior to award. Duluth Travel Inc. holds an active GSA MAS contract (47QMCB25D0001) under SIN 561510. The service fees applicable to this task order are published rates established through GSA's competitive schedule contracting process and are therefore presumed fair and reasonable in accordance with GSAR 538.7102-2(d)(2). Airfare costs reimbursed under this task order are not subject to this price reasonableness analysis, as they are passed through at actual invoiced cost with no markup. The VA is receiving additional FSS pricing discounts on this task order award. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted. Commercial travel agent services are widely available, making it especially important for market research to identify potential sources that are operationally ready to quickly provide travel agent support aligned with VA's specific parameters for Beneficiary Travel. The required support includes booking refundable airfare, coordinating airline-provided accommodation (such as wheelchair assistance), adhering to VA restrictions on advance booking windows, delivering itineraries within required timeframes, and following VA-mandated communication, invoicing, reconciliation, and documentation practices. VA reviewed its requirements for Beneficiary airline travel against the standard services listed under GSA Special Item Number (SIN) 561510, Travel Agent Services. This review identified 21 MAS contract holders offering commercial air travel booking support, of which 14 are small businesses. All 21 companies provide traditional travel agency services intended for broad federal travel use. While MAS contracts awarded under SIN 561510 reflect an ability to provide general commercial air travel support to federal agencies, holding such a contract does not by itself demonstrate the capability required to rapidly and reliably provide enterprise-wide Beneficiary Travel support for Veterans on a national level. Of the 21 MAS contract holders reviewed, only Duluth was found to have the established unique VA aligned processes, specialized VA knowledge, and direct VA experience necessary to immediately support VA's Beneficiary Travel program at this scale. Duluth currently performs both general VA travel and Beneficiary Travel booking services VA-wide as a subcontractor under CONUR, VA's current travel booking contract, and is the only SDVOSB-certified holder under SIN 561510. Other companies may provide general federal commercial travel support but lacked VA-specific workflow alignment, operational readiness, and the ability to meet the time-critical itinerary standards required to prevent missed medical appointments and disruptions in Veteran care continuity. Market research did not identify any other SDVOSB- or VOSB-certified holder under SIN 561510 with demonstrated Beneficiary Travel experience. This market research also confirmed Duluth as the only SDVOSB holding an FSS contract under SIN 561510 that addresses all operational needs for Beneficiary Travel, consistent with VA's Veterans First priorities under VAAR subpart 819.70. Under 38 U.S.C. 8127 8128 and VAAR 819.70, VA must give priority consideration to certified Service-Disabled Veteran-Owned Small Businesses (SDVOSBs), then Veteran-Owned Small Businesses (VOSBs), before other sources when awarding contracts, BPAs, and orders against VA and GSA Federal Supply Schedules, consistent with VAAR 808.004-70(a). Efforts did not identify additional sources, beyond GSA MAS SIN 561510 holders, with established contracts and processes to provide Federal Travel Regulation-compliant common air carrier travel. The Government determined that although multiple commercial vendors exist, soliciting offers beyond Duluth is not practicable, as Duluth is the only company with existing capabilities aligned to immediately support VA's operational needs. Based on this research, the results support limiting sources and proceeding with award of an FSS task order to Duluth Travel Inc. Any other facts supporting the justification. The Government requires uninterrupted access to commercial air travel booking services to ensure eligible Veterans can travel to authorized medical appointments when air transportation is necessary. The service provider must accurately complete itineraries within specified timeframes and coordinate special accommodations needed by Veterans to travel safely. Any delay in establishing contracted support with a qualified company would directly impact Veterans who depend on timely travel coordination for scheduled care, and these functions are essential to prevent missed appointments and disruptions in care delivery. The VHA Beneficiary Travel Program relies on predictable, timely air travel arrangements when commercial flights are the only viable method of reaching required medical services. Without an established vendor capable of meeting VA's operational requirements, Veterans may experience delayed or cancelled travel, resulting in postponed treatments, complications in continuity of care, and potential adverse clinical outcomes. Because many medical appointments involve specialized treatment not available locally, failure to secure timely travel coordination creates a risk of unmet medical needs. This urgency is further supported by operational requirements of the Beneficiary Travel Program, emphasizing timely itinerary return, coordination of travel accommodations, and compliance with VA communication and documentation expectations. Delays in contracting would prevent VA from issuing approved itineraries within established timeframes, disrupt coordination processes, and increase the likelihood of missed flights, appointment cancellations, and inefficient travel planning. Given these conditions, any lapse in service would result in unacceptable disruption to Veteran access to medically necessary care, consistent with the unusual and compelling urgency described in Section 3. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made. Because this action is based on unusual urgency rather than a durable sole-source condition, VA will take the following steps to restore competition for future requirements: The Government will continue to assess the Beneficiary Travel/Common Carrier Airfare requirement to determine whether future acquisitions can be competed. As part of this effort, the program office may conduct further outreach to travel service companies listed under GSA MAS SIN 561510 to evaluate their interest and ability to meet VA's long-term Beneficiary Travel requirements. Future actions may include refining requirements, issuing Requests for Information (RFIs), and ongoing monitoring and engagement with industry. As VA's needs evolve, the Government may further evaluate whether a competitive acquisition strategy, set-aside determination, or broader contract vehicle is feasible. If additional capable vendors are identified, VA may pursue competitive action in accordance with applicable procurement regulations for its long-term needs.